Privacy Policy

LHH GENERAL PRIVACY STATEMENT

Last Updated: August 15, 2024

GENERAL INFORMATION

LHH has a strong commitment to respecting your privacy and protecting your personal information. In this privacy statement ("Statement"), we provide you with details about how we collect, use, disclose, and protect your personal information when you visit this website or when you access or use any applications, services, or features made available by us through or in connection with this website. This General Privacy Statement applies to LHH, its subsidiaries, and all entities within LHH.

LHH is a part of Adecco Group AG, based in Zürich, Switzerland, the largest Human Resources services provider in the world. LHH includes all entities within the Adecco group which operate under the LHH brand name ("LHH," "we," "us"). Our portfolio of brands and business lines includes LHH Career Transitions & Mobility, LHH Leadership Development, the LHH International Center for Executive Options (ICEO), LHH Consulting, LHH Insights, LHH Recruitment Solutions (including Accounting Principals, Ajilon, Paladin, Parker + Lynch, Spring Professional, Badenoch & Clark, Hired), Ezra, and General Assembly.

LHH may supplement this General Privacy Statement with other privacy notices, for example, if you register for services seeking an interim staffing placement, you will receive the LHH Recruitment Solutions Candidate Privacy Notice. If you are receiving LHH Career Transition services through your employer, you will receive the LHH Career Transitions Candidate Privacy Notice.

OUR CONTACT DETAILS AS THE DATA CONTROLLER OF YOUR PERSONAL INFORMATION

The Data Controller of your personal information is the LHH entity that provides you with the LHH services. You can contact the Data Controller for each LHH entity or service by emailing privacy@lhh.com or by using the applicable form below.

INFORMATION WE COLLECT ABOUT YOU.

We need to collect information about you to provide you with the Services or the support you request. The type of information we collect can vary depending on the Services that you are accessing, and the country from which you access them. We will inform you of the specific purposes for collecting your personal information at the time of collection, such as to verify your identity, process your payment, deliver the products or services you requested, or communicate with you.

We collect and use your personal information for the following purposes, depending on the services that you access or use:

- To verify your identity, deliver the products or services you requested, or communicate with you about your account or service status.

- To send you marketing communications about opportunities, products, or services offered by us and our affiliated companies, with your consent or as permitted by law.

- To provide you with personalized content, recommendations, and features based on your interests, preferences, and usage of our services.

- To perform analytics and research to improve our services, develop new products and services, measure, track, and analyze trends and usage in connection with your use or the performance of our services.

- To protect our services and comply with our legal obligations, such as to prevent fraud, enforce our agreements, or respond to lawful requests for information from the government or through legal process.

You can withdraw your consent or opt out of any of these purposes at any time by contacting us using the information below or by following the instructions in our communications. If you withdraw your consent or opt out, we will stop processing your personal information for that purpose, unless there is another legal basis for us to do so.

Information You Provide to Use or Purchase our Services.

We collect the following categories of information about you when you purchase or register for our Services, request information on our website, communicate with us, answer our surveys, or otherwise use our Services, including:

• Identification Information, such as: Your name. In some instances, we will also collect additional proof of identity such as government-issued identification like a passport or driving license.

• Contact Information, such as: email address, phone number, and postal address.

• Location Information, such as: Country and city of residence; office location.

• Employment Information, such as: information relating to your current, past, or prospective employment or professional experience (e.g. job history, performance evaluations), and educational background, qualifications, references, training data, salary data, benefits information, survey responses, dependent and beneficiary information.)

• Financial Information, such as: account information, customer correspondence, purchase, or transaction orders.

• Usage Information, such as: marketing preferences, transactions, products, or services purchased/used.

Information You Provide to Enhance Your Experience

You can choose to provide us with additional information to improve your user experience when using our Services:

• We collect information that you voluntarily provided to us, including survey responses and suggestions for improvements.

Information We Collect from Your Use of our Services

We collect information about you and the devices you use to access the Services, such as your computer, mobile phone, or tablet. The information that we collect includes:

• Geolocation Information.The location of your device, including your IP address, device language, and location of your network provider. This may include precise geolocation information. For more information and to learn how to disable collection of precise geolocation information, please see below.

• Device Information, . Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Services.

• Internet or other electronic network activity information. Information about how you use our Services, including your access time, browser type and language, country and language setting on your device, IP address, the domain name of your Internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your use of the Services, your search terms, and the website you visited before you visited or used the Services, if applicable.

• Inferences drawn from any of the information we collect to create a profile about you that may reflect, for example, your preferences, characteristics, and behavior, including for account security purposes or to enhance our Services to you such as to help prevent fraud.

HOW WE USE YOUR PERSONAL INFORMATION & FOR WHAT LEGAL BASIS

We only collect and use your personal information when we have a legal basis to do so, and when it is necessary or appropriate for the purposes we have identified. We consider the following factors when determining what is necessary or appropriate:

- The nature and sensitivity of the personal information.

- The expectations and interests of the individuals.

- The benefits and risks for the individuals and LHH.

- The availability of less intrusive or alternative means of achieving the same purposes.

- The legal and regulatory requirements and industry standards that apply to LHH.

Our legal bases for collection include:

• Consent: When you have given consent for one or more specific purposes. For example, LHH may require your consent to process your data for electronic marketing activities under applicable laws. You can withdraw your consent at any time by contacting us.

• Contractual Necessity, : When processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract. For example, to allow LHH to provide a service to you, such as career transition, leadership development, or recruitment solutions.

• Legal Obligation: When processing is necessary for compliance with a legal obligation to which LHH is subject. For example, LHH may need to disclose your personal information to a regulator or law enforcement agency, or to verify your identity with government-issued identification.

• Vital Interests: When processing is necessary to protect your vital interests or those of another natural person. For example, in medical emergencies where LHH needs to process personal information to ensure the health and safety of individuals.

• Public Interest or Official Authority: When processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in LHH. For example, LHH may process personal information to comply with applicable laws or regulations, or to respond to lawful requests for information from the government or through legal process.

• Legitimate Interests: When processing is necessary for the purposes of the legitimate interests pursued by LHH, except where such interests are overridden by your fundamental rights and freedoms. For example, LHH may process personal information to provide, maintain, and improve our Services, to develop new products and services, to measure, track, and analyze trends and usage in connection with your use or the performance of our Services, to conduct surveys and collect feedback about our Services, to protect our Services and comply with our legal obligations, or to communicate with you about opportunities, products, services, offered by us and our affiliated companies.

When LHH requests personal information directly from you, you are not obligated to provide it. However, if you choose not to provide this information, in some circumstances, LHH or our clients may be unable to provide certain products or services. For example, we may be unable to process your service delivery or employment.

When and with whom we share your information

We may share the information described in the "Information We Collect About You" section with the following categories of service providers and third parties:

With our Affiliates and Group Companies

• With our group companies and corporate affiliates, for the reasons outlined above, and as it is necessary to provide our Services to you. For example, we may share your information internally for our legitimate business interests to provide you with enhanced services from LHH, to understand how you engage with our Services to help make our Services better for you, and to help us provide Services tailored to your preferences.

With Third Parties

• With service providers who help us provide, maintain, and improve our Services (e.g., service providers who host or support our IT systems; premises management companies; call center service providers; security providers; video conferencing providers; suppliers of service-related tools such as assessments, or practice interviews, virtual job try outs, etc.)

• With our advertising/analytic partners that run advertising campaigns, analyze our site, and track metrics on our behalf or in connection with our Services.

Business Transfers and Corporate Changes

• To a subsequent owner, co-owner, or operator of one or more of the Services; or

• If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

Safety and Compliance with Law

• If we believe that disclosure is reasonably necessary (i) to comply with applicable law, regulation, legal process or governmental request; (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

With Others with Your Consent

• With your consent. For example:

  • At your direction or as described at the time you agree to share.

  • When you authorize a third-party application or website to access your information.

Aggregated and Anonymized Information

• We also may share (within our group of companies or affiliates, or with service providers or other third parties) aggregated and/or anonymized information that does not specifically identify you or any individual user of our Services.

How long we retain your information.

We retain your information only as long as is necessary for the purposes identified in the Privacy Statement, including providing you with the Services, complying with applicable law and legal obligations, and defending our legal rights.

YOUR RIGHTS

Some regional, national, and state laws confer rights relating to personal information. Residents of certain jurisdictions may have the following rights.

Access, Correction and Erasure Requests:

You have the right to:

• ask us to confirm whether we are processing your personal information and receive information on how your data is processed.

• obtain a copy of your personal information.

• request that we update or correct your personal information.

• request that we delete personal information in certain circumstances.

Right to Object to Processing:

You have the right to request that LHH cease processing of your personal information: for marketing activities, including profiling,

• for statistical purposes.

• where such processing is based on our legitimate business interests, unless we can demonstrate a compelling legitimate basis for such processing, or we need to process your personal information for the establishment, exercise, or defense of a legal claim.

Right to Restrict Processing:

You have the right to request that LHH limit the processing of your personal information:

• while LHH is evaluating or in the process of responding to a request by you to update or correct your personal information where such processing is unlawful, and you do not want LHH to delete your data.

• where LHH no longer requires such data, but you want us to retain the data for the establishment, exercise, or defense of a legal claim.

• where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request.

• Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.

Right to Object to Sale and Share:

You have the right to request that LHH not sell or share your personal information.

Data Portability Requests:

You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.

Right to Withdraw Consent:

You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails or contacting privacy@lhh.com.

Right to Object to Profiling and Automated Decision Making:

You have the right to not be subject to a decision based solely on automated processing. Processing is "automated" where it is carried out without human intervention and where it produces legal effects or significantly affects you. Automated processing includes profiling.

Complaints:

If you want to present a complaint or have concerns about our data practices or the exercise of your rights, you may either contact LHH at privacy@lhh.com or the data protection supervisory authority in the country of your residence if applicable. For the EEA, the supervisory authorities are available at the European Data Protection Board’s website. For the UK, the supervisory authority is available at ico.org.uk

Submitting Requests:

If you have questions about data protection or if you wish to contact our Data Protection Officer, or to exercise any of your rights related to your personal information, please fill in the applicable form:

Your requests may also be submitted in writing to privacy@lhh.com or to the Privacy Office at 4800 Deerwood Campus Parkway, BLDG 800, Jacksonville, FL 32246.

We will respond to all such requests within the time permitted by law.

Please note that we will not respond to any request unless we can appropriately verify the requester's identity. Additionally, certain personal information may be exempt from such rights pursuant to applicable data protection laws. Requests are free; however, we may charge you a reasonable fee for multiple, duplicative, or extremely large copies of data that you request.

YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION

Disabling Cookies

You can opt out of the use of cookies on our website by using your browser at any time. Most browsers allow you to view, manage, delete, and block cookies for a website. You can find specific guidance on how to control cookies for common browsers linked below:

• Google Chrome

• Mozilla Firefox

• MacOS Safari Desktop or Microsoft Edge

• For information on additional browsers and device types please seehttp://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/

To learn more about certain cookies used for interest-based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit:

• Digital Advertising Alliance in the US

• Digital Advertising Alliance of Canada

• European Interactive Digital Advertising Alliance

• Australian Digital Advertising Alliance

Managing Analytics cookies

You can opt-out of having your anonymized browsing history within our websites or applications recorded by analytics cookies. We use the following service provider on certain of our websites and you can learn more about their privacy policies and how to opt-out of their analytics cookies by clicking on the link: Google Analytics: Google’s Opt-Out page

You will need to set your preferences for each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings.

Please note, by disabling cookies, you may not be able to take full advantage of the services offered by our website. For more information, please visit our Cookie Policy.

Disabling Geolocation.

By default, all browsers will ask your permission before sending geolocation data to websites. It is possible however to accidentally change your browser’s settings to enable geolocation by default. In any case, you can completely disable geolocation in your browser using the following methods:

Disable Geolocation on Firefox (desktop and Android)

1. Enter about:config into the URL bar and click “I accept the risk” (desktop only).

2. Type geo.enabled into the Search box and then double-click its entry to set its Value to false.

Disable Geolocation on Chrome (desktop)

Go to Menu (≡) -> Settings -> Advanced -> Privacy and security -> Content settings -> Location and toggle “Ask before accessing (recommended)” to Blocked.

Disable Geolocation on Chrome (Mobile)

The same as above, except go to Menu (⋮) -> Settings -> Site Settings -> Location.

Disable Geolocation on Safari (macOS)

Go to Safari (top left on Task Bar) -> Preferences… -> Websites - > Location. Select “Deny” for any listed websites you do not want to your geolocation. To prevent all websites from accessing geolocation data in the future, select When visiting other websites: -> Deny.

Disable Geolocation on Safari (iOS)

Go to Settings > Privacy > Location Services -> toggle button off.

Disable Geolocation on Microsoft Edge

Edge is a Windows Store app, so to disable geolocation go to Window’s Start -> Settings -> Privacy -> Location and toggle “Location” to Off.

Disable Geolocation on Microsoft Internet Explorer

Go to Menu (cog icon to top right) -> Internet options -> Privacy tab -> Location and check “never allow websites to request your physical location” -> OK.

Disable Geolocation on Opera

Go to Menu -> Settings -> Websites -> Location and select “Do not allow any site to track my physical location.”

Do Not Track. Currently we do not alter our information collection and use practices in response to Do Not Track signals.

COMMERCIAL E-MAILS & COMMUNICATIONS

Where we send marketing or other communications to you, you may opt out of receiving any further communications by contacting us or using the ‘unsubscribe’ or ‘opt-out’ function when available. You can also exercise your opt-out right at any time by contacting us using the information listed in the “Contact Information” section below and providing the following information: your name, your email address, a contact telephone number, the marketing communications you would like to opt out of receiving.

HOW WE PROTECT YOUR PERSONAL INFORMATION.

We take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration, or destruction, and (ii) keep personal information accurate and up to date as appropriate.

LHH employs a robust team of dedicated information security professionals responsible for managing LHH's security program. This team is responsible for, monitoring our systems for potential intrusions, responding to potential incidents, regularly reviewing, and updating the security controls LHH uses to protect data, and providing training on LHH's information security program.

We require third parties with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information.

In the event of a security incident, LHH will notify regulators and/or consumers as required by applicable laws and regulations.

USE OF ARTIFICIAL INTELLIGENCE TO SUPPORT OUR BUSINESS.

LHH is deeply committed to leveraging AI technologies to enhance our services while upholding the highest standards of privacy, ethics, and transparency. These technologies are integrated into our business and administrative operations to enhance efficiency, improve service quality, and provide personalized experiences, all while safeguarding your privacy and maintaining our ethical obligations. Below, we detail how AI is employed across our operations:

Automated Customer Service

We employ AI-driven chatbots to enhance our customer service capabilities, offering immediate responses to frequently asked questions, guiding users to relevant resources, and ensuring a smooth handover to human support when necessary. These chatbots are meticulously designed and continuously refined to ensure they respect user privacy while delivering top-tier service. We monitor and update these systems regularly to ensure they remain aligned with our ethical standards and service expectations.

Automated Task Nudging

Our AI systems can provide automated "nudges" to remind users to complete tasks, helping to enhance productivity and engagement. These nudges are designed with user privacy in mind, ensuring that reminders are relevant, non-intrusive, and respectful of user autonomy. We carefully control the data used for these nudges, ensuring it is processed in a secure and ethical manner.

Data Analysis and Reporting

Our AI systems analyze large volumes of data to generate insights that inform our business strategies and decision-making processes. These insights allow us to better understand market trends, customer behavior, and operational metrics, enabling us to refine our offerings and optimize internal processes.

We are committed to ensuring that all data processed by our AI systems is handled with the utmost care, adhering to stringent data protection principles to protect your privacy and maintain data integrity.

Identification of Emerging High-Demand Roles

AI is employed to identify emerging high-demand roles that align with our users' interests and experience. By analyzing market trends and user data, our AI systems suggest new opportunities that may benefit our users' career development. We take great care to ensure that this process respects user privacy and is conducted in an ethical, transparent manner, with a focus on providing value to our users without compromising their trust.

Document Management

AI enhances our document management systems by enabling the efficient organization, categorization, and retrieval of documents. We have implemented robust security measures to ensure that all documents are protected from unauthorized access, and our AI systems are designed to process data in a manner that is fully compliant with applicable privacy laws and ethical standards.

Meeting Transcription and Summarization

We leverage AI tools to transcribe and summarize meetings accurately. These tools capture discussions and provide concise summaries, facilitating the review of key points and follow-up actions. We ensure that these tools are used in a manner that respects the privacy of all participants, with stringent consent, access controls and secure data handling practices in place.

Document Drafting

AI technologies are used to support our drafting and revision of documents, enhancing the speed and accuracy of document preparation. We are committed to ensuring that these AI-driven processes operate within a framework of ethical guidelines, protecting the confidentiality and integrity of all information handled.

Content Creation

AI assists us in several content creation tasks, including:

Voice and Style Alignment

Dubbed Translation in Videos

Contextual Translation of Text

Privacy and Ethical Commitment

Our commitment to privacy and ethics is at the core of our use of AI technologies. We adhere to the highest standards of data protection and privacy, implementing advanced safeguards to ensure that all data processed by our AI systems is secure and handled with the utmost integrity. Our AI practices are designed to minimize data collection and ensure that any data used is necessary, proportionate, and aligned with our ethical principles.

We are also committed to transparency in how we use AI technologies. You have the right to be informed about how your data is utilized in AI processes, and we offer options to opt-out or request more information as needed. Our goal is to leverage these technologies to enhance your experience, while always putting your privacy and ethical considerations first.

If you have any questions or concerns about our use of AI technologies, or if you would like to learn more about how we protect your data, please contact us at [Contact Information].

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

If you receive services from an LHH office outside the United States, the data controller for that office transfers the personal information relating to your services to LHH in the United States pursuant to data transfer agreements when required by applicable laws or regulations. The data controller may also maintain a local copy of your personal information when so required by applicable laws or regulations. Although the data protection laws of various countries may differ from those in your own country, we will take appropriate steps to ensure that your personal information is handled as described in this Statement and in accordance with the law.

Data Privacy Framework Notice

Lee Hecht Harrison LLC (LHH USA, LHH) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. LHH has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal information received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. LHH has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

LHH is responsible for the processing of personal information it receives, under the Data Privacy Framework, and subsequent transfers to a third party acting as an agent on its behalf. LHH complies with the Data Privacy Framework Principles for all onward transfers of personal information from the EU, United Kingdom, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over LHH’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-US Data Privacy Framework (Swiss-U.S. DPF). In certain situations, LHH may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.

In compliance with EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DP, LHH commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal information received in reliance on the EU-U.S. DPF, or the UK Extension to the EU-U.S. DPF or the Swiss-U.S. DPF should first contact LHH at privacy@lhh.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, LHH commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC)} with regard to unresolved complaints concerning our handling of personal information received in reliance on the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Under certain conditions, more fully described on the Data Privacy Framework website at https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf (Opens in a new tab), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

No Collection of Information From Children

Our Website is not intended for use by children under 13 years of age. We do not solicit or knowingly collect any information from visitors under 13 years of age, and please do not use the Websites if you are not yet 13. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us immediately through the contact information below.

CHANGES TO THIS STATEMENT

We may modify this Statement sometimes. When we make material changes to this Statement, we will post a link to the revised Statement on our site's homepage. You can tell when this Statement was last updated by looking at the date at the top of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site. Use of the site, any of our products and services linked to it, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.

CONTACT INFORMATION FOR QUESTIONS OR CONCERNS

If you have any questions or concerns, please contact us by sending an email to privacy@lhh.com or fill in the applicable form:

APPENDIX A ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF RESIDENTS OF CERTAIN COUNTRIES AND US STATES

This Appendix provides additional information for individuals residing in countries and U.S. states that have enacted privacy laws giving certain additional rights to residents of those jurisdictions. The U.S. states include California, Colorado, Connecticut, Utah, Virginia, and Nevada. The countries include Brazil and Hong Kong.

This Appendix outlines certain additional information that LHH is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws. This Appendix will control to the extent it conflicts with any provision in the main body of this Statement.

ADDITIONAL PROVISIONS APPLICABLE TO RESIDENTS OF RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, UTAH, AND VIRGINIA

Collection of Personal Information / Notice at Point of Collection

Residents of California, Colorado, Connecticut, Utah, and Virginia may request information about the personal information that we collect, disclose, “sell,” and/or “share” with third parties. In this context, “sale” has a broad definition and includes the conventional meaning of disclosing your personal information in exchange for money, as well as disclosing it in exchange for any other thing of value. We do not “sell” your personal information in the conventional sense, but we may disclose data points such as your behavior on our website to our marketing or analytics service providers. Certain categories of personal information collected are required for us to provide you with the requested products or services, and if you choose not to provide us with such information, we may not be able to provide you with these products or services. If consent is required, we will obtain your consent before selling or sharing your personal information.

The chart below summarizes the categories of personal information we have collected in the past 12 months, the sources for those categories of personal information, the business or commercial purposes for which the information was collected, the categories of third parties with whom the information may have been “shared,” as permitted by law, and whether the information was “shared” with a third party for a business or commercial purpose within the past 12 months.

Right to Opt-Out of “sharing” / “sale” – Do Not Sell My Personal Information

Residents of California, Colorado, Connecticut, Utah, and Virginia may request that we not disclose their personal information to third parties in certain circumstances. Specifically, these states’ laws allow you to opt out of (1) the use of your personal information to serve you interest-based, targeted advertisements (referred to as “sharing” for cross-context behavioral advertising in California), and (2) the “sale” of your personal information. If you would like to make a request for us to delete or to stop “selling” your personal information, please fill in the applicable form:

You also may call our toll-free telephone number: 1-800-611-4LHH, email privacy@lhh.com or send a letter to the Privacy Office at 4800 Deerwood Campus Parkway, BLDG 800, Jacksonville, FL 32246.

When the privacy office receives your request, they may ask you to verify your identity by asking you to provide your name, the email address and/or phone number associated with your LHH services. Once they have verified your identity, they will promptly fulfill your request.

If you would like, you may designate an authorized agent to make a request on your behalf. To designate an authorized agent, please submit an order issued by a court, a document submitted by a barred attorney, or a formal certified document issued by an official governmental agency.

Sensitive Personal Information

We limit the use of your personal information to that use which is necessary to perform reasonably expected services or as required by law.

The Right to Non-Discrimination

The CCPA (California Consumer Privacy Act) prohibits a business from treating a consumer differently because the consumer exercised a right conferred on him/her by the CCPA. We welcome you to exercise your rights under the CCPA, and we will not discriminate against you for doing so.

Financial Incentive Notice

LHH does not offer a financial incentive for the collection, sale, or deletion of personal information. As detailed in this Statement, LHH collects personal information from users to fulfill their service requests. LHH also collects personal information for marketing and other purposes as permitted by applicable law.

ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF BRAZIL RESIDENTS OR CITIZENS

To the extent you are located within Brazil or in any way subject to the Brazilian General Data Protection Law – Federal Law nº 13709/18 (“LGPD”), the provisions indicated below should be read and applied to the processing or your personal information accordingly. Unless stated otherwise in this Annex, the remainder of the Privacy Statement shall not vary and shall remain in full force and effect.

Data Subjects Rights

Under certain circumstances, you have the following rights under the LGPD in relation to your personal information:

• Right to Information: right to obtain clear, transparent, and understandable information on how we use your personal information;

• Right of confirmation and access: right to receive confirmation and access your personal information held by us about you;

• Right of rectification: right to have your personal information corrected if they are outdated, inaccurate or incorrect and/or to complete them;

• Right of anonymization, blocking or deletion: Anonymize, block, or eliminate any unnecessary or excessive data or data processed in noncompliance with the applicable law;

• Right to withdraw consent at any time for consent-based data processing: right to withdraw your consent to the processing of your personal information when such processing is based on consent;

• Right to data portability: right to request copying, transferring your personal information to another database in accordance with further regulation of the local authority;

• Right to receive information about public and private entities: right to receive information about public and private entities with which your personal information is shared;

• Right to object: right to oppose any processing activity based on a legal basis other than consent in case there is violation of the LGPD;

• Right to review automated decisions: right to review of decisions, whenever they are based only on automated processing of personal information, by a natural person, whenever it affects your interests;

• Right to file a complaint with your local Data Protection Authority or consumer protection entities.

If you have questions about data protection or if you wish to contact our Data Protection Officer, or to exercise any of your rights related to your personal information, please fill in the applicable form:

You also may email privacy@lhh.com.

Legal Bases

LHH usually relies on one of the following legal bases when processing your personal information for the purposes indicated in the Global Privacy Statement in accordance with Article 7 of the LGPD:

• Data subject’s consent (art. 7, I)

• For compliance of a legal or regulatory obligation (art. 7, II)

• Whenever necessary for the performance of a contract or preliminary procedures relating to contracts in which the data subject is a party (art. 7, V)

• Whenever necessary for the legitimate interests of the controller or of third parties, except in the prevalence of fundamental rights of the data subject (art. 7, IX).

International Transfers

Where we transfer information that originates in Brazil to a country outside of Brazil, we will take steps to make sure such transfer is carefully managed to protect your privacy rights:

• Transfers within the LHH Group of Companies may be covered by an agreement entered into by members of LHH (an intra-group agreement) which contractually obliges each member to ensure that your information receives an adequate and consistent level of protection wherever it is transferred within LHH in accordance with the LGPD.

• Where we transfer your data outside of the LHH Group of Companies, including to other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your information, such as standard contractual clauses or binding corporate rules. In the lack of instructions from the local supervisory authority, we may follow the standard models adopted under the European Union or by other competent authorities until then.

• We can also transfer personal information to countries recognized as providing adequate legal protection or where alternative arrangements are in place to protect your privacy rights.

If you want further information on the specific mechanism used by us when transferring your personal information out of Brazil, or you have questions about data protection or if you wish to contact our Data Protection Officer, or to exercise any of your rights related to your personal information, please fill in the applicable form:

You also may email privacy@lhh.com.